# Global Passive Safety System Ltd. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 12-0005
- **title:** Global Passive Safety System Ltd. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2012-05-01
- **effective on:** Not available
- **summary:** 12-0005 response to Global Passive Safety System Ltd. concerning 173.315.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-12-0005.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-12-0005.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-12-0005
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120005.pdf
**body:**

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U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
MAY 0 1 2012
Mr. Andy Abrams
Global Passive Safety System Ltd.
761 West Sproul Road, Suite 208
Springfield, PA 19064
Ref. No.: 12-0005
Dear Mr. Abrams:
This responds to your January 4, 2012letter requesting clarification of the Hazardous Materials
Regulations (HMR; 49 CFR Parts 171-180) applicable to hose assemblies. Specifically, you
inquire whether a metallic hose assembly made with a corrugated tube of 316SS and an outer
braid of 304SS with a working pressure of 400+ p.s.i. and a burst of 2000 can be used in
liquefied petroleum gas (LPG) and anhydrous ammonia (NH3) cargo tanker service.
In accordance with § 173.315(n)(2), for a cargo tank motor vehicle in other than metered
delivery service, there are no specific HMR provisions dictating the material from which a
delivery hose must be comprised. However, Pipeline and Hazardous Materials Safety
Administration (PHMSA) does specify in§ 178.337-9 the requirements (burst pressures,
weights, damage protection, free from leaks, etc.) for piping, valves, hoses, and fittings on MC
331 cargo tanks intended to contain compressed gases. Further, the hose identification,
inspection, and testing requirements for a delivery hose assembly on a cargo tankused to
transport liquefied compressed gases are specified in § 180.416 of the HMR, including the
rejection criteria in paragraph (g). Additionally, it is the responsibility of the person offering a
hazardous material for transportation to ensure that the packagings and its appurtenances
(piping, valves, hoses, fittings, etc.) are compatible with its lading.
Please be aware that these hoses may be subject to the Occupation Safety and Health
Administration (OSHA) Standards in 29 CFR, and specific questions about requirements for
equipment such as a hose should be directed to OSHA and any applicable state regulatory
authorities. However, a review of 29 CFR § 1910.111(b )(8) states that hoses used in ammonia
service shall conform to the joint Agricultural Ammonia Institute - Rubber Manufacturers
Association (RMA) Specifications for Anhydrous Ammonia Hose. Subsequently, a cursory

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analysis of the documents published by RMA make no mention of a metallic hose assembly as
is described above. For further assistance, you may contact Jeffrey J. Wanko, Safety Engineer
for OSHA Directorate of Enforcement Programs, by phone at (202) 746-2667 or email at
JWanko@dol.gov.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
--7.'M71/YU :v?X)z-~
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
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<<<PAGE 3>>>

January 4 2012
Director- Office of Hazardous Materials Standards
Pipeline and Hazardous Materials Administration
US Department of Transportation
1200 New Jersey Avenue, SE Building 2nd Floor
Washington, DC 20590
Letter of Interpretation
Dear Sir/Madam
We are writing in connection with the regulations set forth below to inguire specifically if a
metallic hose assembly made with a corrugated tube of 316SS and an outer braid of 304 SS
with a working pressure of 400+PSI and a burst of 2000 can be used in LPG and NH3
Cargo Tanker service.
A. GPSS USA Regulatory Position: Under 49 CFR 315, the following Passive Device
Requirements are promulgated.
(2) Cargo tank motor vehicles in other than metered delivery service. A cargo
tank motor vehicle in other than metered
delivery service must have a means to automatically shut off the flow of product
without the need for
human intervention within 20 seconds of an unintentional release caused by a
complete separation of a liquid delivery
hose (passive shut-down capability).
(i) Designed flow of product through a bypass in the valve is acceptable when
authorized by this subchapter.
(ii) The design for the means to automatically shut off product flow must be
certified by a Design Certifying Engineer.
The certification must consider any specifications of the original component
manufacturer and must explain
how the passive means to shut off the flow of product operates. It must also
outline the parameters (e.g., temperature,
pressure, types of product) within which the passive means to shut off the flow of
product is designed to operate.
All components of the discharge system that are integral to the design must be
included in the certification. A
copy of the design certification must be provided to the owner of the cargo tank
motor vehicle on which the equipment
will be installed.
(iii) Installation must be performed under the supervision of a Registered
Inspector unless the equipment is installed
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and removed as part of regular operation (e.g., a hose). The Registered Inspector
must certify that the equipment
is installed and tested, if it is possible to do so without damaging the equipment,
in accordance with the Design
Certifying Engineer's certification. The Registered Inspector must provide the
certification to the owner
of the cargo tank motor vehicle.
(3) Cargo tank motor vehicles in metered delivery service. When required by the
table in paragraph (n)(l) of this section,
a cargo tank motor vehicle must have an off-truck remote means to close the
internal self-closing stop
valve and shut off all motive and auxiliary power equipment upon activation by a
qualified person attending the unloading
of the cargo tank motor vehicle (off-truck remote shut -off).
It is our position that the metallic hoses we are providing are being used on DOT application and
OSHA jurisdictions. As such, they are subject to the standards set forth under 49 CFR 173.315
which does not specify hose material or out of service standards. It is our position that when we
provide hoses in OSHA jurisdictional service, we comply with the hose performance standards
and even comply with 1910.111 (b )(8)(iv) independent of additional valves since our system has
internally integrated shut-off valves. We recognize that you can not opine over OSHA standards
but there is some overlap.
B. Technical Standards- Why is a metallic hose equal to or greater than a rubber hose?
There are many different types of hose available on the market, including metal, rubber,
composite, PTFE, and fabric. There are eight factors that make a metal hose a superior
choice to rubber hose:
1. TEMPERATURE EXTREMES
If either the temperature of the media going through the hose or the surrounding
atmospheric temperature is very cold or hot, metal may be the only material that
can withstand such temperature extremes.
2. CHEMICAL COMPATIBILITY- NO ERROR IF USED IN EITHER LPG OR
NH3
Metal hose can handle a wider variety of chemicals than most other hose types. If the
hose will be exposed to aggressive chemicals (either internally or
externally), metal hose should be RECOMMENDED. Case in point: In the article below
a RUBBER LPG hose was erroneously used in NH3 service because the layline on the
hose was worn away.
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<<<PAGE 5>>>

Posted on Thu. Jul. 16. 2009
Ammonia cloud kills woman, injures 7
Leak at chemical plant near SWansea prompts evacuation
D<lnna Petrey got a call just after 8 a.m. Wednesday
from her son. telling her the ohernical plant across
the street had sprung a leal<.
'I grabbed my 7-year-old grandoan. Hunter, and our
dog, Oreo. and put them in the car," she said.
At the end of the driveway, she glanced left and was
stunned.
•n looked fike a huge colton boD. It was so thick. you
couldn1 see anything through il' said Petrey, 50,
who liVes acros~ from Tanner Industries, just south of
Swansea in Lexington County.
Petrey didn't kntrw il hut a motorist alreadY had
driVen into that doud - a vast poisonous mist of a
deadly ohern~cal called anhydrous ammonia, typically
used in cleaning products- and hadn't made I! oul
Jacqueline Patrice Gmynrd, 38. of Wagener couldn't
get her car out of the fog and tried to flee on fool
according to the Lexington County Sheriff's
Department Her bodY tater was found next to her
car.
Wednesday's leak also sent seven people to IJren
hospitals and prompted the evacuation of numeroun
nearby homes. By late afternoon, roughly 20 homes
were being tested lor contamination, though
authorities found none.
Had a metallic hose been used the incident would have been avoided and no injury would
have occurred.
3. PERMEATION CONCERNS
Nonmetal hose is susceptible to gas permeation through the hose wall and into the
atmosphere. Metal hose, on the other hand, does not allow
permeation. If containing the gases inside the hose is important, metal hose may be required.
4. POTENTIAL FOR CATASTROPHIC FAILURE
When a metal hose fails, it usually develops small holes or cracks. Other hose types tend to
develop larger cracks or come apart completely. If a sudden hose
failure is potentially catastrophic, a metal hose may help minimize the effects of a failure by
leaking product at a slower rate.
5. FIRE SAFETY -EXCESSIVE HEAT
Other hose types will melt when exposed to fire, while metal hose maintains its integrity up
to 1300 degree F.
6. FRIGID/CRYOGENIC CONDITIONS- EXCESSIVE COLD
LPG and NH3 hoses frequently are used in below zero conditions which can cause or
contribute to hose tube failures. Metallic hoses are designed with a substantially wider
temperature range.
7. ACHIEVING FULL VACUUM
Under full vacuum, metal hose maintains its shape while other hose types may collapse.
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8. FLEXIBILITY IN FITTING CONFIGURATION DUE TO WELDING
Metal hoses are welded which avoids the risk of crimping and crimp failures ..
C. Other Standards- OSHA speaks in a very limited manner to this issues.
1. In 1926.153(h)(7) - Hose shall be designed for a working pressure of at least 250 p.s.i.g.
Design, construction, and performance of hose, and hose connections shall have their suitability
determined by listing by a nationally recognized testing agency. The hose length shall be as short
as practicable. Hoses shall be long enough to permit compliance with spacing provisions of
paragraphs (h)( 1) through ( 13) of this section, without kinking or straining, or causing hose to be
so close to a burner as to be damaged by heat.
2. OSHA 29 1910.1ll(b)(8)(i)
• Hose used in ammonia service shall conform to the joint Agricultural Ammonia
Institute - Rubber Manufacturers Association Specifications for Anhydrous Ammonia
Hose.
• 1910.111(b)(8)(ii)
• Hose subject to container pressure shall be designed for a minimum working pressure
of350 p.s.i.g. and a minimum burst pressure of 1,750 p.s.i.g. Hose assemblies, when
made up, shall be capable of withstanding a test pressure of 500 p.s.i.g.
• 1910.111(b)(8)(iii)
• Hose and hose connections located on the low-pressure side of flow control of
pressure-reducing valves shall be designed for a bursting pressure of not less than 5
times the pressure setting of the safety relief devices protecting that portion of the
system but not less than 125 p.s.i.g. All connections shall be so designed and
constructed that there will be no leakage when connected.
• 1910.111(b)(8)(iv)
• Where hose is to be used for transferring liquid from one container to another, "wet"
hose is recommended. Such hose shall be equipped with approved shutoff valves at
the discharge end. Provision shall be made to prevent excessive pressure in the hose.
3. State Regulations
The use of Rubber hoses is also being phased out of many state regulations. For
example in Texas, Texas Administrative Code, TITLE 16 ECONOMIC
REGULATION PART 1 RAILROAD COMMISSION OF TEXAS, CHAPTER 9
LP-GAS SAFETY RULES, SUBCHAPTER B LP-GAS INSTALLATIONS,
CONTAINERS, APPURTENANCES, AND EQUIPMENT REQUIREMENTS
RULE §9.143 Bulkhead, Internal Valve, API 607 Ball Valve, and ESV Protection
for Stationary LP-Gas Installations with Individual or Aggregate Water Capacities
of 4,001 Gallons or More provides:
g) In addition to NFPA 58 §§5.9.6 and 6.9.6.1, by February 1, 2003, rubber flexible
connectors which are 3/4-inch or larger in size installed in liquid or vapor piping at an
existing liquid transfer operation shall have been replaced with a stainless steel flexible
connector. Stainless steel flexible connectors shall be 60 inches in length or less, and shall
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4. comply with all applicable LP-Gas Safety Rules. Flexible connectors installed at a new
installation after February 1, 2001, shall be stainless steel.
NFPA 58 Section 2.4.6 provides the working/operational pressures ofhoses but
makes no mention except to provide that the must be corrosion resistant such as
stainless steel.
Therefore, we are of the opinion that the metallic hose that we are offering is compliant with the
DOT, OSHA, NFPA and Federal/State regulatory standards. We welcome any comment or
opinion on our conclusion.
Regards~
Global Passive Safety Systems Ltd.
761 West Sproul Road, Suite 208
Springfield, P A 19064
Toll Free 855-GPSS-USA (855-477-7872)
M-267-307-0949
F- (267) 937-2081
E-Mail: AndyAbrams@GPSafetySystems.Com
WWW.GPSAFETYSYSTEMS.COM
GP~
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